Federal

  • January 04, 2023

    Ga. Biz Can't Recoup Peanut Wagons' Excise Tax, Court Told

    A Georgia company can't recoup federal heavy truck and trailer excise taxes it paid on its sale of peanut-drying semitrailers, the U.S. government told a federal court, arguing the company's ability to freely use public highways and other factors render it liable for the tax.

  • January 04, 2023

    3rd Circ. Preview: NCAA Athlete Pay Fight Tops Jan. Calendar

    Collegiate athletes' fight for pay leads the Third Circuit's argument calendar this month, along with cases tackling the tax deductibility of litigation expenses and whether the "gist of action" doctrine applies in a case against Dick's Sporting Goods. 

  • January 04, 2023

    US Seeks Funds It Says Were Used In Casino Bribery, Tax Plot

    The U.S. government is entitled to $310,000 in laundered funds that a shadowy set of business and political figures used in schemes to avoid taxes and bribe Northern Mariana Islands officials related to a casino project, the U.S. claimed in a lawsuit.

  • January 04, 2023

    Tax Court Sustains $8K Bill For Denied Business Expenses

    Two California residents who challenged an Internal Revenue Service decision to disallow expenses for the depreciation of a car and truck used for business purposes owe $8,200 because they failed to substantiate their spending, the U.S. Tax Court said in a decision released Wednesday.

  • January 04, 2023

    9th Circ. Dismisses Ex-Ariz. Gov.'s ARPA Relief Funds Dispute

    Former Arizona Gov. Doug Ducey's case appealing the federal government's restrictions on pandemic relief funds from the American Rescue Plan Act has been tossed by the Ninth Circuit following Ducey's motion to dismiss.

  • January 04, 2023

    Changes In Lighting Support Federal Energy Refund, Biz Says

    A company earned energy-efficient building deductions by altering lighting system specifications, so an Illinois federal court should deny the U.S. government victory without trial on whether an accompanying refund was erroneous, the owner and his wife said.

  • January 04, 2023

    Treasury Issues Final Regs For Foreign Pension Funds

    The U.S. Treasury Department published final rules narrowing the scope of tax relief available to foreign pension funds for gains or losses on certain U.S. real estate interests while proposing new guidance on other exemptions afforded them.

  • January 04, 2023

    Ex-Biofuel Execs Say US Sitting On Docs As They Seek Retrial

    Two former executives of a biofuels company who were sentenced to prison for falsely claiming millions in biodiesel tax credits asked a Pennsylvania federal court to force the government to reveal documents they say could trigger a new trial.

  • January 04, 2023

    Liens Apply To NJ Properties In $16M Tax Row, Court Says

    Tax liens assessed by the IRS in its efforts to collect a man's $16.2 million in taxes can be applied to two New Jersey properties, a federal court ruled, finding that they effectively belonged to him for purposes of the liens. 

  • January 04, 2023

    Florida Woman, US Propose $818K FBAR Settlement

    A Florida woman would pay nearly $818,000 to end a case seeking penalties against her for failing to file reports of her foreign bank accounts under the proposal she and the U.S. government submitted in federal court.

  • January 03, 2023

    Israeli Law Firm Takes GILTI Regs Challenge To DC Circ.

    An Israeli law firm and its sole shareholder will continue fighting the global intangible low-taxed income regulations set forth in the Tax Cuts and Jobs Act by taking their case to the D.C. Circuit.

  • January 03, 2023

    Atty Lied During Tax Fraud Trial, Investment Adviser Says

    An investment adviser's former attorney gave false testimony during a tax fraud case that the U.S. government is now using to seek $2.2 million in civil penalties for unreported offshore accounts, the adviser said in a lawsuit in Arizona federal court.

  • January 03, 2023

    IRS Won't Flag FATCA Filings That Don't Have ID Numbers

    Foreign financial institutions that report information on U.S. account holders to the Internal Revenue Service without including the taxpayer identification numbers associated with those accounts won't be flagged for noncompliance, the agency announced.

  • January 03, 2023

    Chrisleys Can't Extend Prison Report Date In Bank Fraud Case

    A Georgia federal judge denied a request by Todd and Julie Chrisley, stars of reality TV show "Chrisley Knows Best," to delay their prison report date, but did order the government to respond to their motions for bond pending an appeal of their bank fraud and tax evasion convictions.

  • January 03, 2023

    IRS Defines Terms For Clean Vehicle Credit

    The clean vehicle tax credit can apply to a consumer who took possession of a qualified electric vehicle on Jan. 1 or later, the IRS said in a notice defining the incentive's "placed in service" term that can unlock the incentive.

  • January 03, 2023

    Ex-Pharma CEO Asks Justices To Review $1M In Tax Penalties

    A former pharmaceutical CEO asked the U.S. Supreme Court to review a Third Circuit decision upholding $1 million in Internal Revenue Service penalties against him for failing to report a Swiss bank account, saying the circuit wrongly considered his actions reckless.

  • January 03, 2023

    Riding Circuit: January's Notable Appellate Arguments

    Circuit courts will kick off 2023 with oral arguments by parties questioning the authority given to the Centers for Disease Control and Prevention, pushing back against U.S. Patent and Trademark Office policy on patent reviews and claiming Chinese nationals were wrongly targeted for alleged economic espionage.

  • January 03, 2023

    GoDaddy Parent Asks Tax Court For $16M In R&D Credits

    The parent company of web hosting platform GoDaddy petitioned the U.S. Tax Court for help securing $16.3 million in research and development tax credits, saying its software and product development expenses qualified for a now-expired tax break.

  • January 03, 2023

    IRS Increases Standard Mileage Rate By 3 Cents

    The Internal Revenue Service raised its standard mileage rate for business use to 65.5 cents per mile in the new year, a three-cent increase.

  • January 02, 2023

    Federal Tax Cases To Watch In 2023

    In the coming year, the U.S. Supreme Court will hear multiple high-profile tax cases involving attorney-client privilege and foreign bank account penalties, while lower courts will continue to grapple with the legitimacy of IRS rulemaking. Here, Law360 reviews the top federal tax cases to watch in 2023.

  • January 02, 2023

    International Tax Policy To Watch In 2023

    As global policymakers continue to develop an international tax overhaul, it will be up to governments around the world to determine whether and how much of the plan to enact in 2023. Here, Law360 runs down international tax policies to watch for in the coming year.

  • January 02, 2023

    Federal Tax Policy To Watch In 2023

    A divided Congress will return to Capitol Hill in late January with little hope of eking out a comprehensive bipartisan tax agenda that can reach President Joe Biden's desk during the last two years of his presidency.

  • January 02, 2023

    7 Supreme Court Cases To Watch In 2023

    The new year brings a host of hot-button cases for the U.S. Supreme Court justices, who will tackle everything from President Joe Biden's student debt relief plan to Section 230 immunity for Big Tech companies over the next six months before the summer recess. Here, Law360 highlights the big-ticket items.

  • December 29, 2022

    Brokers Can Wait For Regs To Report Digital Assets

    Brokers won't be required to report additional information about sales of digital assets as required by a new law until Treasury and the IRS issue final regulations clarifying which digital assets qualify and giving instructions for reporting, according to an IRS announcement.

  • December 28, 2022

    Treasury Issues Interim AMT Guidance Including Safe Harbor

    The U.S. Treasury Department has issued interim guidance for the new 15% corporate alternative minimum tax, including a safe harbor method for determining whether the levy applies to companies for the upcoming year.

Expert Analysis

  • Telehealth Providers Must Beware Of Fraud As Industry Grows

    Author Photo

    A recent fraud charge against a telehealth executive highlights the rise we're seeing in telefraud scams during the industry's pandemic growth, and there are some steps that all health providers should take to stay clear of potentially illegal arrangements, says LaTawnda Moore at Dinsmore.

  • Parsing New Int'l Tax Reporting Rules For Pass-Throughs

    Author Photo

    Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.

  • A Look At Global Tax Enforcement Developments: Part 2

    Excerpt from Practical Guidance
    Author Photo

    Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.

  • A Look At Global Tax Enforcement Developments: Part 1

    Excerpt from Practical Guidance
    Author Photo

    Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.

  • What The Judiciary's Font Recommendations Can Teach Us

    Author Photo

    The D.C. Circuit's recent soft prohibition on Garamond and the ensuing debates about courts' font preferences should serve as a helpful reminder of a larger point — every departure from convention in legal writing carries some level of risk, says Spencer Short at Stradley Ronon.

  • 2 Income Tax Loopholes Congress Should Close

    Author Photo

    To raise revenue for proposed infrastructure improvements and make the tax law fairer, the Biden administration and Congress should close an income tax loophole that allows an asset owner to bypass capital gains tax upon death and another that essentially allows taxpayers to make tax‑free gifts to grantor trusts, says Richard Kinyon at Shartsis Friese.

  • High Points Of IRS' New Employee Retention Credit Guidance

    Author Photo

    Dana Fried at CohnReznick examines recent IRS guidance on the employee retention credit, which includes a helpful new rule enabling more employers to qualify for the credit by allowing them to exclude some pandemic relief from gross receipts, but its exclusion of related individuals' wages from qualified wages for certain corporate owners is disappointing.

  • Prepare For More Audits Of Tax Info And Withholding Filings

    Author Photo

    Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.

  • 9th Circ. Adds Pressure To Reject Substance Over Form

    Author Photo

    The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.

  • How Tax Code Changes Affect State AG Settlement Talks

    Author Photo

    Meghan Stoppel and Gianna Puccinelli at Cozen O'Connor discuss how newly implemented tax code regulations that allow companies to deduct some payments made to resolve a government investigation or prosecution will change settlement negotiations with state attorneys general.

  • NFTs May Come With Rewards, But Also Legal Risks

    Author Photo

    While some buyers of nonfungible tokens are experiencing enormous returns on their investments, those just entering the market should proceed with caution, and be sure to understand the risks related to contracts, taxation, intellectual property and money laundering regulations, says Anne-Laure Alléhaut at Patterson Belknap.

  • Problems To Avoid When Forming Your 2nd Real Estate Fund

    Author Photo

    There are a number of considerations when moving from your first real estate fund to subsequent funds during post-pandemic growth, particularly if the aggregate regulatory assets under management of the funds exceed $110 million or if additional country jurisdictions will be involved, say Matt Ertman and Max Brunner at Allen Matkins.

  • IRS Ruling Opens Runway For Stalled Carbon Capture Deals

    Author Photo

    A recent Internal Revenue Service ruling that clarifies how multiparty ownership affects eligibility for the carbon sequestration tax credit should accelerate the pace of project financing transactions that were held up by lingering uncertainty, and should increase the pool of projects into which tax equity will consider investing, say attorneys at Orrick.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.